National Hydrogen Strategy Issues Papers

Existing regulations would not manage potential carbon emissions of a large-scale national hydrogen industry. The only national mechanism available to curtail emissions is the Safe-guard Mechanism which was established to assist the effectiveness of the Emissions Reduction Fund. However, being a new industry, it is uncertain what level of carbon emissions would be tolerated under the Mechanism. In addition, the fact that Australia’s deemed Emissions Reduction Target of 26-28% by 2030 is comparatively weak in terms of Australia’s fair share of global emissions reduction, it is unlikely that extra emissions from a new industry would concern many policy-makers to the level that is required for ambitious climate change mitigation.

It is crucial to keep a focus on the end-point of a large-scale hydrogen industry, and that is to enable carbon emissions from natural gas (methane) to be reduced and the natural gas industry to be steadily down-graded. Due to inappropriate market dynamics in Australia, availability of gas as an energy source is now in jeopardy, stimulating proposals for further exploration and extraction of natural gas, conventionally and unconventionally. However, it would be preferable to re-organize the market to provide more gas domestically rather than spending on infrastructure to unlock more subterranean gas during development of the hydrogen industry (https://www.michaelwest.com.au/the-ultimate-gouge-why-australia-the-worlds-1-exporter-now-imports-gas/) Mining, treatment, storage, distribution and use of methane gas, and fugitive emissions result in equivalent green-house gas potency to that of coal-fired power generation (https://www.dea.org.au/wp-content/uploads/2018/12/DEA-Oil-and-Gas-final-28-11-18.pdf)so that unlocking more gas is only delaying emissions reduction.

• continuing coal-mining beyond that required for coal-fired power generation prolongs local communities’ exposure to toxic air pollution from coal dust
• continuing coal-mining would delay the closure and rehabilitation of coal mines which is an ever- increasing cost the longer closure is delayed.
• the technology available does not allow sufficient carbon capture at an affordable price, although CCS from this new industry would be more efficient and cleaner than that of current CCS systems, for example, from coal combustion for power generation. Full cost accounting for adverse health effects must be considered whenever assessing costs related to coal-mining.
• judging from difficulties encountered in establishing CCS elsewhere, communities are unlikely to tolerate a lengthy process to establish a new industry which would have a limited life as a transition industry.
• the concept of “technological neutrality” whereby considerations such as carbon emissions, carbon storage, health safety, pollution and sustainability are ignored has no place in current decision-making for energy production and will not be accepted by local communities.

Using water from de-salination plants appears to have cost, quality and emissions advantages as long as power for the plant is gained from renewables https://www.mdpi.com/2076-3298/5/2/24/htm. Purification of re-cycled water is an alternative provided the water had not been intended for domestic or agricultural use, given the emerging scarcity of water associated with predictions of drought in certain regions and increasing surface temperatures.

Balancing water use between the competing demands will be an ever-increasing problem in Australia. There are already huge disputes between upstream business interests and downstream communities and environmental interests. The value of environmental flows to underpin a healthy ecological balance should not be underestimated as a robust, intact ecological balance is the basis of life in Australia and on this planet. Thus, unless there is copious rainwater available, desalination is the preferred source.

It will be necessary to continue a National Hydrogen Strategy to manage the many stages from further research to development. As this technology is essentially being developed to provide energy with next-to-zero emissions, it would be counter-productive not to provide widespread environmental safe-guards and natural resource protections. The Strategy would need to have a clear policy statement which embraced the urgent need for ambitious action on climate change in order to protect the health of future generations. State-based EPA’s are better placed to deal with environmental approvals until a more effective National EPA, which has been advocated by DEA, is developed. State-based EPA’s are better placed to monitor and report environmental breaches which in many cases could be referred nationally.

It would be difficult to mandate standards and regulations until further trialling of the many processes involved. However, three standards which could be predicated at this stage would be 1) low to zero carbon emissions, 2) water preservation and 3) affordability.

As an organization, DEA would very much like to continue engagement with the National Hydrogen Strategy as development of this resource has important implications for the future of human health. We would like to continue receiving progress reports on all aspects of development as the ultimate goal of this industry is to reduce greenhouse gas emissions sufficiently to safeguard health.

Communities in regional and remote areas are usually well-informed through the many news outlets, environmental and support groups via regular on-line media and bulletins. Many communities now have Sustainability groups to which updates are disseminated. It would be important for the National Hydrogen Strategy to seek and maintain contact with these organizations, both by electronic media and by community-based forums. These need to be expertly conducted as many regional communities initially reject advice from “outside”.

Governments and Industry have been remiss in the past in not gaining community “licence” to proceed with major projects. Community involvement and meetings with Industry over new renewable projects has reversed this trend recently. It is essential that forums are conducted to explain the rationale of new enterprises, the science, and both the immediate and long-term environmental impacts. These actions could be set into a code of conduct which would then also include up-dating of progress and the communication of any emerging untoward outcomes. Industry should learn from previous conduct of the gas and coal enterprises and not repeat the heavy-handed, bullying processes which decimated individual and community livelihoods.

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• that engagement with the community and a clear presentation of the facts with evidence helps greatly in achieving community and widespread acceptance
• that presentation of false information and disregard for climate change mitigation portends community disharmony and conflict leading to disruptions, delays and huge additional costs.
• that gaining support of indigenous communities which have valued land culturally and spiritually for thousands of years is an essential pre-requisite to harmonious development
• that mining and the resources sector must take into consideration costs to the communities’ health and the local and distant environment when calculating the value of its operations. In many cases, the government is effectively heavily subsidising the industry by covering these costs.